Finding Text
2024-008 – Non-Compliance and Significant Deficiency in Internal Control over Compliance - CARES Institutional (HEERF) Federal Awards
Assistance Listing Number: 84.425F
Program Name: COVID-19 Education Stabilization Fund: HEERF – Institutional Portion
Pass Through Identifying Number: N/A
Award Year: 2023-2024
Federal Agency: U.S. Department of Education
Criteria: In accordance with 2 CFR § 200.305(b) of the Uniform Guidance, which applies to the HEERF grants, grantees must seek to minimize the time between drawing down funds from the G5 system and applying those funds to support a grant award’s activities. Consistent with this requirement, grantees must maintain grant funds in interest-bearing accounts, and any interest earned on grant funds above $500 per year must be remitted to the Federal government. In accordance with 2 CFR.303(a) of the Uniform Guidance, which applies to the HEERF grants, non-Federal entities are required to establish and maintain effective internal controls over federal awards.
Condition: No internal controls were identified in regards to appropriate cash management for the Higher Education Emergency Relief Fund Institutional Aid.
Cause: Only one person prepared, reviewed, and submitted the cash drawdown requests. In addition, the College did not appropriately monitor the cash deposits for interest earned.
Effect: The college earned interest on the funds drawn from the G5 system that were in excess of $500 and did not comply with requirement to return funds. As a result, the college may be required to return the excess funds.
Questioned costs: $31,057.
Recommendation: It is recommended that the client establish controls in order to ensure that federal awards are prepared and reviewed by multiple personnel before processing. CRI will recommend controls be in place to ensure that there is a minimum period between grant drawdowns and grant expenditures.
Views of Responsible Officials: Management agrees with the findings. See corrective action plan beginning on page 108.